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given you a prior opportunity to contest the liability.
Therefore, IRC 6330(c)(2)(B),a statutory bar against
contesting the liability in the context of a collection
due process hearing, maybe applicable. If you are
interested in Audit Reconsideration, please follow
procedures outlined in the enclosed publication 3598,
and send that information to the address indicated.
Your collection due process hearing will consist of a
discussion on collection alternatives only.
For me to consider alternative collection methods such
as an installment agreement or offer in compromise, you
must provide any items listed below. In addition, you
must have filed all federal tax returns due.
• A completed Collection Information Statement
(Form 433-A for individuals and/or Form 433-B
for businesses.)
• Signed tax return(s) for the following tax
periods. Our records indicate they have not
been filed:
Type of Tax: 1040
Period or Periods: 12/31/1999, 12/31/2000,
12/31/2001, 12/31/2002, 12/31/2003,
12/31/2004, 12/31/2005
• Proof of estimated tax payments for the pe-
riod(s) listed below: 12/31/2006
Please send me the items above within 14 days from the
date of this letter. I cannot consider collection
alternatives in your hearing without the information
requested above. I am enclosing the applicable forms
and a return envelope for your convenience. [Repro-
duced literally.]
Petitioner did not respond to the settlement officer’s April
24, 2006 letter or provide any of the information requested in
that letter.
On June 13, 2006, the settlement officer held a telephonic
Appeals Office hearing (hearing) with petitioner. During that
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Last modified: November 10, 2007